Kovach v. District of Columbia
Court of Appeals of the District of Columbia
805 A.2d 957 (D.C. Ct. App. 2002)
Kovach (plaintiff) was cited by a traffic camera for running a red light and paid the resulting fine. The police department later removed the camera after finding it caught an unusually large number of drivers, and agreed to dismiss the fines of everyone who had been cited but hadn't yet paid. Kovach sued the District of Columbia (defendant) to recover $1.5 million in fines already collected from drivers who, like him, had run the light and paid. The trial court granted judgment for the District on res judicata grounds, reasoning Kovach's earlier payment barred him from now contesting the dismissal of others' unpaid fines. Kovach appealed.
Whether collateral estoppel bars a party from contesting his own paid traffic fine after the government dismisses the fines of others who were similarly cited but had not yet paid.